All industrial permits sources were reviewed to insure that appropriate requirements had 

been applied and that these requirements constituted RACT. The following are thirteen 

sources that had the highest sum of emissions of combined NOx, SO2, and Particulate. 

Particulate was used because PM2.5 emission factors are limited. These sources were 

reviewed to verify that the sources were subject to RACT levels of controls.

Industrial emissions were reviewed to see if there was a possibility of any additional 

controls that could change the attainment date from the end of 2009 to the end of 2008. 

No additional controls were found. Table 15 shows that no possible reductions will result 

in a 2008 attainment. 

Brach’s Confections

Company Number 0300

Full Compliance Evaluation: April 24 2007. The source was in compliance.

Allowable Emissions: Particulate 46.31 tons per year

NOx 41 tons per year

SO2 0.18 tons per year Natural Gas Combustion only

This source is subject to the following rules.

1. 40 CFR Part 60 Subpart DC – Standards of Performance for Small Industrial –

Commercial-Institutional Steam Generating Units

2. Particulate Rule 10 

3. Opacity Rule 3

4. Particulate BACT 4-8(e)(2)b

Three boilers on site are fired by natural gas only.

One 21.32 million BTU/hr boiler

One 15.7 million BTU/hr boiler 

One 30.1 million BTU per hour boiler 

The 15.7 million BTU/hr Boiler is subject to 40CFR Part 60 Subpart Dc-Standards of 

Performance for Small Industrial-Commercial-Institutional Steam Generating Unit.

Process equipment emits 2.5 TPY of particulate at maximum operating rate. Process 

emissions are controlled by baghouses. 
2

East Tennessee Natural Gas

Company Number 5340

Full Compliance Evaluation March 29, 2007. The source was in compliance

Emissions Particulate is 2.24 tons per year. All particulate is PM2.5.

Allowable NOx 48.20 Tons per year. 

Subject to the following as adopted into the Chattanooga Air Pollution Control Ordinance

1. 40 CFR Part 60 Subpart GG Standards of Performance for Stationary Gas 

Turbines.

2. Chattanooga Air Pollution Control Ordinance Rule 15 Adoption of NSPS 

Both turbines burn pipeline natural gas and have been stack tested. The allowable 

NOx limit in the NSPS is 150 ppm. The older turbine which was tested in 1991 

demonstrated NOx emissions of 63 ppm or 3.7 lb/hour. The newer turbine which 

was tested in 2002 demonstrated NOx emissions of 14.2 ppm or 2.72 lb/hr. If both 

turbines ran 8760 hours, the potential emissions would be 28.12 tons per year. 

Fuel sulfur has also been demonstrates as 0.02 % which is well below the NSPS 

allowable of 0.08%. 

Particulate is likely to be overestimated as discussed in the emission inventory 

document that said that particulate emissions from combustion of natural gas are 

significantly overestimated. 
3

Erlanger Medical Center

Company Number 0150

Full Compliance Evaluation completed on October 23, 2007. The source was in 

compliance 

Allowable/ Actual Emissions Particulate 11.87 TPY

NOx 71.92 TPY

SO2 18.00 TPY

SO2 is limited by the permit to 500,000 gallons on Number 2 fuel oil with 0.5% sulfur. 

There are 4 permitted boilers that provide steam for a large medical center. The boilers 

are fired on natural gas but use Number 2 fuel as a backup fuel. Depending on steam 

demand one or two boilers will be operated at a time. Though the facility is permitted for 

Number 2 oil with 0.5% sulfur oil, the facility used 3600 gallons and the number 2 oil 

was 0.1865 % Sulfur in the last year. 

This source is subject to the following rules.

1.40CFR Part 60 Subpart Dc Small Industrial-Commercial-Institutional 

Steam Generating Units

2. Particulate Rule 27.3

3. Opacity Rule 3 10% Opacity limits

6. SO2 Rule 13.2 Quarterly Sulfur Reports Required 
4

Erlanger Medical Center

Company Number 0150

Full Compliance Evaluation completed on October 23, 2007. The source was in 

compliance 

Allowable/ Actual Emissions Particulate 11.87 TPY

NOx 71.92 TPY

SO2 18.00 TPY

SO2 is limited by the permit to 500,000 gallons on Number 2 fuel oil with 0.5% sulfur. 

There are 4 permitted boilers that provide steam for a large medical center. The boilers 

are fired on natural gas but use Number 2 fuel as a backup fuel. Depending on steam 

demand one or two boilers will be operated at a time. Though the facility is permitted for 

Number 2 oil with 0.5% sulfur oil, the facility used 3600 gallons and the number 2 oil 

was 0.1865 % Sulfur in the last year. 

This source is subject to the following rules.

1.40CFR Part 60 Subpart Dc Small Industrial-Commercial-Institutional 

Steam Generating Units

2. Particulate Rule 27.3

3. Opacity Rule 3 10% Opacity limits

6. SO2 Rule 13.2 Quarterly Sulfur Reports Required 
5

Memorial Hospital RACT

Company Number 2010

Full Compliance Evaluation was completed on December 21, 2006. The source was in 

compliance. 

This permit applies to the three 500 hp Johnson boilers that provide steam for Memorial 

hospital. Natural gas is used to fire the boilers with number 2 fuel oil as a backup fuel in 

case of natural gas curtailment. By permit condition, only 2 boilers can be in operation at 

a time. 

Allowable Emissions Particulate 8.20 lb/hr

NOx N/A

SO2 10.15 lb/hr

Actual Emissions Particulate 1.235 TPY

NOx 12.57 TPY

SO2 44.46 TPY

Available Emission Factors show direct PM2.5 as 0.8820 TPY

This source is subject to the following:

40CFR Part 60 Subpart Dc- Standards of Performance for Small 

Industrial-Commercial-Institutional Steam Generating Units.

The NSPS limits the sulfur in the fuel oil to 0.5% 

Rule 8.2 limits particulate to 8.2 lb/hr

Rule 13 limits SO2 to 300 ppm. 
6

Rock Tenn Converting Company

Company Number 47-065-3455

Full Compliance Evaluation completed on December 12, 2006. Source was in 

compliance 

Allowable Emissions Particulate 23.074 TPY

NOx 96.76 TPY

SO2 349.19 TPY

Allowable emissions are based on 2% sulfur content and 3,500,000 gallons per year. 

Actual oil sulfur content is normally considerably less than 2%. Natural gas is the 

primary fuel and is used when it is available and is cost competitive. 

This source is subject to the following;

40 CFR Part 70 Operating Permit Program

The following local rules;

1. Particulate Rule 26.6

2. Opacity Rule 3

3. VOC Rule 25.3

4. SO2 4-60(d)(9)

Actual emissions from the boilers in the last year are as follows

Particulate 15.25 TPY

NOx 73.92 TPY

SO2 174.97 TPY

The lower actual emissions occurred because the facility used Number 6 fuel with a 

sulfur content of 1.61 % for the first 6 months and 0.99% for the second six months of the 

year. 

This source is a candidate for contingency measures. Specifically, the oil sulfur limit may 

be further restricted. 
7

Signal Mountain Cement

Company Number 47-065-3070

Reconstructed 2001

Full Compliance Evaluation by Chattanooga-Hamilton County APCB November 

26, 2006. The source was found to be In Compliance.

Full Compliance Evaluation by Region 4 March 13, 2007 the source was found to 

be In Compliance.

Stack Tests 

NOx Sept 2001 and Jan 2007

Particulate Sept 2001

SO2 Sept 2001

CO Sept 2001

Opacity Sept 2001 

Emissions Particulate 64.18 tons per year

NOx 1651 tons per year 

SO2 0

Subject to the following as adopted into the Chattanooga Air Pollution Control Ordinance

1. NOx SIP Call

2. 40 CFR Part 63 Subpart LLL National Emissions Standards for Hazardous Air 

Pollutants from the Portland Cement Industry

3. 40 CFR Part 60 Subpart F Standards of Performance for Portland Cement 

Plants

4. 40 CFR Part 60 Subpart Y Standards of Performance for Coal Preparation 

Plants

5. 40 CFR Part 64 Compliance Assurance Monitoring 

6. 40 CFR Part 70 Operating Permit Program

7. Chattanooga Air Pollution Control Ordinance Rules 2.6, Rule 27, Rule 26, 

and Rule 18 . 

COMS on Kiln Baghouse. Observed Opacity between 0 and 5%.

Pressure differential recorded as required by the permit. All pressures differentials 

in compliance

Periodic opacity readings recorded as required by the permit. No reading in 

violation. 

NOx monitored using back end oxygen correlation in compliance. Recorded at at 

least 1 minute intervals.
8

Nine Baghouses subject to CAM. One equipped with COMs. Eight require 

pressure drop readings.

Daily qualitive visible observations for all emissions units except for those 

equipped with COMs are required. If opacity is greater than 10 % then a daily 

Method 9 reading is required. If the limit for a particular unit is exceeded, then a

Method 9 reading is required daily until the unit is in compliance. 
9

Archer Daniels Midland Company d/b/a Southern Cellulose Products 

Company Number 3110

Full Compliance Evaluation was completed on November 1, 2006. 

Allowable Emissions Particulate 14.51 lb/hr

NOx No NOx limit for small boilers. Heaters NOx

allowable 0.56 lb/hr (Process Equipment)

SO2 57.71 lb/hr

Actual Emissions Particulate 3.28 TPY

NOx 40.67 TPY

SO2 0.410 TPY

This source is subject to the following rules.

1. Particulate Rule 26.6, 4-8(e)(2)(b), Rule 10 

2. Process NOx Rule 2.4

2. Opacity Rule 3, Rule 26.20

3. SO2 Rule 13
10

Caraustar Mill Group, Inc. d/b/a Chattanooga Paperboard

Company Number 47-065-0700

Full Compliance Evaluation completed on May 3, 2007. The source was in compliance.

Allowable Emissions Particulate 11.42 TPY

NOx 30.078 TPY

SO2 245 TPY

Allowable emissions are based on 2% sulfur content of fuel oil. 

Boiler #2 is subject to 40CFR Part 60 Subpart Dc Standard of Performance for Small 

Industrial-Commercial-Institutional Steam Generating Units

The source is subject to;

40 CFR Part 70 Operating Permit Program

This source is subject to the following local rules.

1. Particulate Rule 26.6

2. Opacity Rule 3

3. VOC Rule 25.3

4. SO2 4-57(a)(1)

5. Particulate Rule 27
11

Ergon Terminaling RACT

Company Number 4040 

Full Compliance Evaluation was completed on July 3, 2007. 

This permit applies to a terminal storage facility for asphalt cement, caustic soda, and 

styrene monomer. On average, 32 barges per year are unloaded per year. There are 

emissions of VOC from the products but the heaters are the sources of PM2.5 precursors 

and direct PM2.5. The facility operates 4 heaters and boilers. These are the following:

Hopkins Thermal Liquid Heater 8.6 million BTU/hr

VA Power Boiler 5 million BTU/hr

VA Power Thermal Liquid heater 6.6 million BTU/hr

Boiler B1 13 million BTU/hr

Allowable Emissions Particulate 8.20 lb/hr

NOx N/A

SO2 10.15 lb/hr

Actual Emissions Particulate 1.41 TPY

NOx 14.12 TPY

SO2 50.13 TPY

Available Emission Factors show direct PM2.5 as 0.8820 TPY

Boiler B1 is subject to 

40CFR Part 60 Subpart Dc- Standards of Performance for Small 

Industrial-Commercial-Institutional Steam Generating Units.

The NSPS limits the sulfur in the fuel oil to 0.5% 

Rule 8.2 limits particulate to 8.2 lb/hr
12

INVISTA S.à.r.l., LLC

Company Number 47-065-3889

INVISTA, at this time consists of three sources. The sources are INVISTA, Kordsa, and 

DuPont. 98.9% of the emissions are from INVISTA. Changes in ownership are such that 

this permit will soon be broken into three. INVISTA will be the only one of the three that 

will be a major source. 

Full Compliance Evaluation completed on May 18, 2006. The source was in compliance. 

Emissions Particulate 40.60 tons per year

NOx 273.27 tons per year

SO2 828.44 tons per year

Subject to the following as adopted into the Chattanooga Air Pollution Control Ordinance

1. 40 CFR Part 64 Compliance Assurance Monitoring 

2. 40 CFR Part 70 Operating Permit Program

3. 40 CFR Part 60 Subpart Dc Standards of Performance for Small IndustrialCommercial-Institutional Steam Generating Units.

4. Chattanooga Air Pollution Control Ordinance 4-8(e)(2), Rule 2, Rule 3, Rule 

10, Rule 13, Rule 26, and Rule 27. 

This source is a major source because of combustion emissions. 

Boilers 1 and 2

Natural Gas Primary Fuel 

Fuel oil limited to 1.830,000 gallons per year in boilers with 0.3 % sulfur.

Monitored by recordkeeping

Opacity limit 10%

Boilers 3, 4, and 5

Bituminous Coal Fuel limited to 112,000 tons per year.

Sulfur limited to 1.25 % by weight.

Particulate limited by Rule 26

Baghouse control.

Sulfur monitored by fuel testing.

Coal-fired boilers demonstrated the same emissions as original tests when Method 

5 was performed as part of the Site Specific Health Based Compliance 

Demonstration

Vaporizers 1, 2, 3, 4, 5, and 6. 

Limited to natural gas and Number 2 fuel oil.

10% opacity limit
13

Limited to 2,000,000 gallons per year.

Fuel oil limited to 0.3% sulfur.

Dowtherm Transport System

Condensers followed by demisters

Continuous Polymerization Line II

Scrubber control 

.

Particulate from polyester flake handling 

Controlled by 9 bag houses and 2 HEPA filters

Particulate from hot chest exhausts of Spinning Machines 201,202,203,211,221,231,241, 

and 251

Controlled by ESPs.

All control systems have required monitoring in the permit to insure that the controls are 

working as designed. 
14

Mueller Company

Company Number 47-065-2150

Reconstructed 1999

Full Compliance Evaluation by Chattanooga-Hamilton County APCB, November 26 

2006. The source was found to be In Compliance.

Full Compliance Evaluation by Region 4, March 13, 2007. The source was found to be 

In Compliance.

Emissions Particulate 47.8 tons per year

NOx 17.14 tons per year 

SO2 3.6 tons per year

Subject to the following as adopted into the Chattanooga Air Pollution Control Ordinance

1. 40 CFR Part 63 Subpart EEEEE National Emissions Standards for Hazardous 

Air Pollutants from the Iron and Steel Foundrys

5. 40 CFR Part 64 Compliance Assurance Monitoring 

6. 40 CFR Part 70 Operating Permit Program

7 40 CFR Part 60 Subpart Cc Standards of Performance for Small IndustrialCommercial-Institutional Steam Generating Units.

8 Chattanooga Air Pollution Control Ordinance Rules, Rule 27, Rule 26, Rule 3, 

Rule 2, Rule 10, Rule 13, Rule 2, Rule 18. 

Pressure differential recorded as required by the permit. All pressures differentials 

in compliance

Bag leak detectors as required by the MACT are in place

Periodic opacity readings recorded as required by the permit. No reading in 

violation. 

Eight baghouses are subject to CAM. These require daily pressure drop readings.

Four emission points are controlled by a HEPA filter in series with a baghouse. 

Foundry visible emissions 10 % except for emissions from buildings and then iyt 

is 5%. 

Foundry landfill visible emissions limit is 10%. 
15

Saint-Gobian Norpro RACT

Company Number 2220

Full Compliance Evaluation completed on December 8, 2006. The source was in 

compliance 

Allowable Emissions Particulate 83.5 TPY

NOx 10 TPY

SO2 72 TPY

Actual Emissions Particulate 10.2 TPY

NOx 3.5 TPY

SO2 20 TPY

This source is subject to the following rules.

1. Particulate Rule 10.3 , Rule 26.3, and 4-8(e)(2)(b)

2. Process NOx Rule 2.4

2. Opacity Rule 3 10% Opacity limits

3. Process gaseous emissions Rule 23

4. SO2 Rule 13.2
16

Southeastern Materials (Shallowford Plant) 

Company Number 6008

Full Compliance Evaluation was completed on June 23, 2006. The source was in 

compliance.

Allowable Emissions Particulate 71.83 TPY

NOx 24.3 TPY

SO2 6.69 TPY

Actual Emissions Particulate 22.1 TPY

NOx 20.5 TPY

SO2 2.25 TPY

Available Emission Factors show direct PM2.5 as 2.25 TPY

This source is subject to the following :

40CFR Part 60 Subpart I Standards of Performance for Hot Mix Asphalt 

Facilities

The NSPS sets a PM emissions limit of 0.04 gr/dscf and a visible emission 

limit of less than 20%.

The facility is subject to the following local Rules;

1. Rule 27.1 which requires particulate BACT applies. The NSPS particulate limit is 

considered as BACT but a 10% opacity limit is required under Rule 27.1

2. Rule 2.4 limits NOx emissions to 300 ppm

3. Rule 13 limits SO2 to 300 ppm. 

The stack test required by the NSPS was conducted in August 1999. 
17